4/2021 Publications

Entity Classification Advice May Aid Pre-Immigration Planning

Tax Notes Article

Severiano Ortiz is quoted in an article discussing IRS Legal Advice Memorandum AM 2021-002, released April 2, 2021, regarding how the IRS will apply its default entity classification rules–a foreign eligible entity will now have a tax classification during a period when a classification is “irrelevant” and the 60-month limitation rule may not apply. Tax Notes. April 13, 2021. Download